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Income Tax Regs., supra. Because petitioner presented no
adequate records or sufficient evidence to corroborate his own
testimony, he may not claim a deduction for his business
expenses.
Petitioner’s Charitable Contributions
Petitioner alleged at trial that he is entitled to a
deduction for “church and charitable” donations. He had no
evidence of any charitable gifts other than his own testimony.
Taxpayers are required to keep records of charitable
contributions of money. Section 1.170A-13(a)(1), Income Tax
Regs., requires substantiation for charitable contribution
deductions. A taxpayer must maintain one of the following: (1)
a canceled check; (2) a receipt or letter from the donee
charitable organization showing the name of the donee, and the
date and the amount of the contribution; or (3) other reliable
records showing the name of the donee, and the date and the
amount of the contribution. Sec. 1.170A-13(a)(1), Income Tax
Regs.
Petitioner testified that “the point of giving is not to
make a worldly claim”. While petitioner’s sentiment is correct,
substantiating a gift does not taint the heart of the giver.
Petitioner’s church and charity donations do not meet the
requirements of section 1.170A-13(a)(1), Income Tax Regs. See
Blair v. Commissioner, T.C. Memo. 1988-581.
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